My advice to you would be - stop trying to invoke the ftc - you obviously don't understand enough about contract law to have any hope of interpreting their regulations.
Is this your professional, legal opinion ? In fact, the Federal Trade Commission was set up for just such consumer protection cases.
Taking things to the FTC is a reasonable step in lodging a formal complaint and establishing a problem pattern if you have a legitimate case.
Every little bit helps establish a pattern.
http://www.ftc.gov/bcp/index.shtml